Privacy Policy

STA International (“STA”) is committed to respecting the privacy rights of our customers and all visitors to our web site (the “Site”). We take this matter very seriously, and have instituted many policies and procedures to insure that none of your privacy rights as stated herein are violated. The following outlines STA’s privacy policy and details the measures we have taken to safeguard and protect your privacy when using our Site. By visiting the STA Site, you are agreeing to the policies detailed below.

This privacy statement sets out our current policies. We may change the content or services found on our Site at any time without notice, and consequently our privacy policy may change at any time in the future. You agree to revisit this page regularly and your continued access to or use of the Site will signify your consent to the changes.

Client Access Site
If you enter into an agreement with us as a result of which you are given a password to use the password protected parts of the Site, we will ask you to provide us with certain up to date data about yourself. We maintain strict security standards and procedures with a view to preventing unauthorized access to your personal data. All our employees and any third parties used by us are required to observe our privacy standards.

The personal details that we use to provide our services, as well as any information taken from you while you are using this Site, will not be passed to any organization outside of the STA group, except as required by court order or applicable law.

Electronic Communication with STA
When you send an e-mail to STA or visit the Site, you are communicating with us electronically. When you send an e-mail to STA, you consent to receive communications from us electronically in response. STA may communicate with you by e-mail, by updating or posting notices on the Site. You agree that all agreements, notices, disclosures and other communications that STA provides to you electronically satisfy any legal requirement that such communication be in writing. All communications with STA become the property of STA.

Use of your e-mail address and mailing address
Your e-mail address may be used by STA to correspond with you about information you may have requested or which may be of interest to you or to notify you about important functionality changes to the Site, and new STA services and special offers and promotions we think you may find valuable. If you would rather not receive this information, or would like to opt-out of receiving e-mail of this kind, simply click on the “Unsubscribe” link that appears at the bottom of any e-mail and follow the simple instructions to have your e-mail address removed from the list of customers who receive such notices. Your mailing address may be used by STA to provide you with print materials you have requested or which may be of interest to you.

Use of Cookies
A cookie is a small piece of information sent by a web site that is saved on your hard disk by your computer’s browser. The cookie holds information a site may need to personalize your experience and to gather web site statistical data, such as which pages are visited, the internet provider’s domain name and country that our visitors come from (e.g. “aol.com” or “msn.com”) and the addresses of the sites visited immediately before coming to and immediately after leaving stagraydon.com. However, none of this information is associated with you as an individual. It is measured anonymously and only in the aggregate. The information in the cookies lets us trace your “clickstream” activity (i.e., the paths taken by visitors to our Site as they move from page to page). Cookies do not capture your individual e-mail address or any private information about you.

STA may use third-party advertising companies to place ads on our web site as well as third party companies to provide tracking and analysis of information and data collected from visitors to our Site. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous and STA reserves the right to provide that information and data to these third parties.

To browse without cookies, you can configure your browser to reject all cookies, or to notify you when a cookie is set. Each browser is different so check the “Help” menu of your browser to learn how to change your cookie preferences. Even without accepting a cookie, you can still access most of the features on STA.

Third Parties
STA International works with third parties to research on its behalf the use and activities on its website. No personal information about you is shared.

External Links
The Site may contain links to other websites which are hosted by and maintained by third parties. We have no control over the content or security of any such site. You link to such websites at your own risk and we make no representations regarding the content of any such website. We cannot be liable for any loss or damage which may arise from the use of such third party websites.

European Privacy
For European Privacy Information, see the Safe Harbor Policy below.

Queries
If you have any difficulties in accessing the Site, then email us at privacy@stacollect.com or write to STA International at our office address set forth below.

About us
STA International is a Delaware company with an office at 1400 Old Country Road, Suite 411, Westbury, NY 11590-5119.

SAFE HARBOR PRIVACY POLICY
STA Credit Corp. (“STA”) values the privacy of its customers, employees and business partners and is committed to safeguarding individual Personal Information (as defined below) in a manner consistent with the laws of the countries in which it conducts business. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles with which STA complies with respect to Personal Information transferred from the twenty five member states of the European Union (“EU”) to the United States.

SAFE HARBOR
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the “Safe Harbor Principles”) to enable U.S. companies to satisfy the requirement under European law that adequate protection be given to Personal Information transferred from the EU to the United States. The European Economic Area has recognized the U.S. Safe Harbor as providing adequate data protection. Consistent with its commitment to protect personal privacy, STA adheres to the Safe Harbor Principles with respect to such transferred information.

SCOPE
This Policy applies to all Personal Information received by STA in the United States from the EU, in any format including, without limitation, on-line, off-line and manually processed data.

DEFINITIONS
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses Personal Information under the instructions of, and solely for, STA or to which STA discloses Personal Information for use on STA’s behalf.

“STA” means STA Credit Corp., its successors, subsidiaries, divisions and groups in the United States.

“Personal Information” means any information or set of information that identifies or is used by or on behalf of STA to identify an individual. Personal Information does not include information that is encoded or anonymous, or publicly available information that has not been combined with non-public Personal Information.

“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life. In addition, STA will treat as Sensitive Personal Information any information received from a third party in which that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the Safe Harbor Principles.

NOTICE: Where STA collects Personal Information directly from individuals in the EU, it will inform them about the purposes for which it collects and uses Personal Information about them, how to contact STA with any inquiries or complaints, the types of non-Agent third parties to which STA discloses that information, if any, and the choices and means, if any, STA offers individuals for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to STA, or as soon as practicable thereafter, and in any event before STA uses or discloses the information for a purpose other than that for which it was originally collected.

Where STA receives Personal Information from its subsidiaries, affiliates or other entities in the EU, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such Personal Information relates. STA obtains Personal Information only as permitted by the Safe Harbor Principles or with the consent of the individual affected. Consent for Personal Information to be collected, used and/or disclosed in certain ways may be required in order for an individual to obtain or use STA’s services. To the extent permitted under the Safe Harbor Principles, STA reserves the right to process Personal Information in the course of providing services to the customers of its overseas affiliate without the knowledge of the individuals involved.

CHOICE: STA will offer individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to be disclosed to a non-Agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

Should STA ever receive Sensitive Personal Information, STA will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-Agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

STA will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

For purposes of this section, STA’s overseas affiliate, the entity to which individuals have disclosed their Personal Information for the purpose of receiving its services (and for whom STA is acting as agent for the purpose of storing and securing the disclosed data) and that affiliate’s third party agents are not non-Agent third parties (use and disclosure by the overseas affiliate of Personal Information received from its customers being subject to its own privacy policy practices, the choices made by its customers with respect to limitations on the use and sharing of such information and the data protection laws of the jurisdiction).

DATA INTEGRITY: STA will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. STA will take reasonable steps to ensure that Personal Information is relevant, accurate, complete, and current for its intended use.

DISCLOSURES AND TRANSFERS: STA does not disclose Personal Information to third parties, except when one or more of the following conditions is true:
· STA has the individual’s permission to make the disclosure;
· The disclosure is necessary and proper in order to provide the services requested by the individual;
· The party to whom the disclosure is made controls, or is controlled by, or is under the common control of, STA;
· The disclosure is to persons or entities for whom STA is providing services, provided the disclosure is consistent with the purpose for which the Personal Information was obtained;
· The disclosure is permitted by law; or
· The Personal Information to be disclosed is publicly available.
STA will obtain assurances from its Agents that they will safeguard Personal Information in accordance with this Policy. Examples of appropriate assurances that may be provided by Agents include: a contract obligating the Agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the Agent, or being subject to another European Commission adequacy finding. Where STA has knowledge that an Agent is using or disclosing Personal Information in a manner inconsistent with this Policy, STA will take reasonable steps to prevent or stop the use or disclosure. When STA transfers personal information to a third party that is acting as STA’s Agent, before doing so STA will ascertain that the third party safeguards Personal Information consistent with this Policy. Transfers of information permitted under this notice, either to third parties or within the STA organization, include the transfer of data from one jurisdiction to another, such as transfers to and from the United States of America.

ACCESS AND CORRECTION: Upon reasonable request, STA will grant individuals reasonable access to Personal Information that it holds about them. In addition, STA will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: STA will take reasonable precautions to protect Personal Information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: STA will conduct compliance audits of its relevant privacy practices to verify compliance with this Policy and the Safe Harbor Principles, and will provide a statement, at least one time each year, signed by STA’s authorized representatives, verifying STA’s adherence to the Safe Harbor Principles.

DISPUTE RESOLUTION: STA will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy. For any dispute that cannot be resolved through STA’s internal process, STA has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principles. In the event that STA or such authorities determine that STA did not comply with this Policy, STA will take appropriate steps to address any adverse effects and to promote future compliance.

LIMITATION ON APPLICATION OF PRINCIPLES
Adherence by STA to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; and (b) to the extent expressly permitted by an applicable law, rule or regulation.

INTERNET PRIVACY
STA considers the Internet and the use of other technologies as valuable tools for communicating and interacting with consumers, employees, business partners, and others. STA recognizes the importance of maintaining the privacy of information collected online and has created a specific Internet Privacy Policy (the “IPP”) governing the treatment of Personal Information collected through web sites that it operates. With respect to Personal Information that is transferred from the EU to the U.S., the IPP is subordinate to this Policy. However, the IPP also reflects additional legal requirements and evolving standards with respect to Internet privacy.

CONTACT INFORMATION
Questions or comments regarding this Policy should be submitted to STA by mail or e-mail as follows:
STA International
1400 Old Country Road
Suite 411
Westbury
NY 11590-5119
privacy@stacollect.com

AMENDMENT OF SAFE HARBOR PRIVACY POLICY
This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the STA web page (http://www.stacollect.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.
To learn more about the Safe Harbor program, and to view STA’s certification, please visit http://www.export.gov/safeharbor/.